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EU REACH adds 16 CMR substances, to be implemented from September 1, 2025! Electronic and electrical enterprises need to conduct timely inspections

Time：

2025-08-18

16 new CMR substances have been added to Annex XVII of the EU REACH regulation, which will officially come into effect on September 1, 2025. The electronic and electrical industry has been particularly affected by this regulatory revision, and companies have conducted comprehensive supply chain inspections in a timely manner to ensure compliance.

On August 11, 2025, the European Commission officially published a new regulation (EU) 2025/1731 in the Official Journal of the European Union, revising the restriction list of carcinogenic, mutagenic, and reproductive toxic (CMR) substances in Annex XVII of the REACH regulation. This time, 16 new Class 1B CMR substances have been added and relevant restriction requirements have been clarified, which will officially come into effect on September 1, 2025.

1、 Core change: 16 new CMR substances added, with clear limit standards

This revision adds 16 new CMR substances (13 specific substances+3 reactive materials) of Class 1B, such as tetrabromobisphenol A, dibutyltin oxide, etc., and also proposes an exemption clause for specific use of isopropylbenzene.

According to Articles 28, 29, and 30 of Annex XVII of the EU REACH Regulation, the newly added CMR 1B substance is subject to the universal concentration limits set by the EU CLP Regulation (EC) No 1272/2008

Classification	limit	Involving substances
Carcinogen Class 1B	≥ 0.1% (weight percentage)	Tetrabromobisphenol A (TBBPA), N, N-dimethylp-toluidine, etc
Mutagen class 1B substances	≥ 0.1% (weight percentage)	Dimethylpropyl phosphate
Reproductive Toxic Substances Class 1B	≥ 0.3% (weight percentage)	Dibutyltin oxide, bisphenol AF (BPAF), etc

It is worth noting that the regulation has added an exemption clause: isopropylbenzene, which was previously listed as a CMR substance, is not subject to this restriction requirement when it is used as a component of aviation fuel (such as kerosene and gasoline) that meets specific industrial standards.

2、 Industry risk: Compliance focus in the electronic and electrical field

Among the newly added substances, many are closely related to the production of electronic and electrical products. The electronic and electrical industry has been particularly affected by this regulatory revision, and the following high-risk substances and their application scenarios need to be given special attention:

Substance name	hazard classification	Typical application areas
Tetrabromobisphenol A (TBBPA)	Carcinogen Class 1B	Printed circuit board (PCB), flame retardant for plastic casing
Dibutyltin oxide	Mutants Class 1B	Electronic equipment polyurethane (PU) foam non halogenated flame retardant
Dimethylpropyl phosphate	≥ 0.3% (weight percentage)	Dibutyltin oxide, bisphenol AF (BPAF), etc
Bisphenol AF (BPAF)	Reproductive toxicity class 1B	Seals, gaskets, and special cable coatings
Dibutyltin Maleate	Reproductive toxicity class 1B	PVC material heat stabilizer, coating catalyst

In addition, other newly added substances such as photoinitiators, epoxy resin catalysts, plasticizers, etc. may also be involved in the material processing of electronic and electrical products. Enterprises need to comprehensively sort out the material composition of their supply chain.

3、 Suggestions for Corporate Compliance Response

Starting from September 1, 2025, 16 CMR substances are prohibited from being sold in the European Union if their concentration in the mixture exceeds the prescribed limit. Enterprises need to act quickly, and Jiayu Testing suggests promoting compliance work from the following three aspects:

Comprehensive investigation of the supply chain

Immediately initiate a full supply chain material screening, focusing on verifying the use of high-risk substances mentioned above, establishing a Bill of Materials (BOM) and Material Database (SDS) to ensure compliance with limit requirements.

Alternative evaluation and validation

Evaluate the feasibility of environmentally friendly alternative materials (such as halogen-free flame retardants, new heat stabilizers, etc.) for restricted substances, and verify the performance and compliance of alternative materials through laboratory testing.

Pre layout for testing and authentication

By leveraging the REACH regulation specific services of third-party testing agencies, precise testing of products and raw materials is conducted, compliance reports are issued, and market access risks are avoided.

Jiayu Testing has a professional testing technology team, equipped with advanced instruments and equipment, proficient in various regulatory standards, and specializes in providing one-stop REACH testing services for various consumer goods such as electronic appliances. Welcome to contact us at 400-9269-886!